ML20128H109
| ML20128H109 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 10/07/1996 |
| From: | Reda R GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9610090240 | |
| Download: ML20128H109 (3) | |
Text
, 'h GENuclear Energy GeneralDecrnc Company P O Box 130. Wimmgwn. NCl'SJ02 910675 M l
October 7,1996 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Subject:
REPLY TO NRC INSPECTION
References:
(1)
NRC License SNM-1097, Docket 70-1113 (2)
NRC Inspection Report 70-1113/96-202, Dated 4/10/96 Thank you for your letter reporting the results of the inspection conducted at our licensed fuel fabrication plant by Messrs. W. Troskoski and D. Stout of your office during the period March 11-15,1996.
Please find in the attachment to this letter our response to observations made concerning our chemical process safety program in the referenced inspection report. The inspection report comments and suggestions are helpful to us in our continuing efforts to improve our chemical process safety programs.
GE will consider these recommendations in our ongoing chemical safety improvement
- programs, Please feel free to call either H. R. Strickler at (910) 675-5721 or myself at (910) 675-5889, if you have further questions.
Sincerely, GE NUCLEAR E R-J.
R. J. Reda, Manager Fuels and Facility Licensing kb1 )
attachment cc: RJR-96-115 G. L. Troup - Region ll P. Ting - Headquarters 9610090240 961007 PDR ADOCK 07001113 C
4 Dodument Control Desk October 7,1996 Page 1 of 2 ATTACHMENT 1 Response to NRC's Inspection #96-202 Item #1:
Evaluate the effect of any potential leak from the new HF facility on the 4
safe operation of the DCP due to the location of the Heating Ventilation and Air Conditioning air intake.
Response
General Electric recognized the need for considering the impact of HF releases on the safe operations of the DCP facility. The HF facility operates using condensing and scrubbing techniques to extract aqueous HF from the off-gas of the UF6 to UO2 ccnversion stream. The flow of the off-gases is easily controlled. The concentration of aqueous HF in the facility does not have the capability to exceed approximately 50% HF. There is no anhydrous HF produced or handled nor are there any processes which are capable of concentrating the HF above its nominal maximum concentration of 50%. The HF building was also designed to reasonably well contain any HF that leaked or spilled.
Notwithstanding the low likelihood and consequence of an HF spill / release, this potential event was considered in the design and operation of the facility.
The HF facility was located relative to the DCP and other facilities based on the wind frequency and direction. The prevailing wind is from the southwest, however, more careful examination of the relative frequency distribution and magnitude for Wilmington, North Carolina (GE Wilmington Environmental Report NEDO 31664 dated 5/1/89 as supplemented 5/2/96) shows that most all of the wind directions experienced at the site would not be expected to produce an interaction between the DCP and HF facilities.
The location selected therefore minimizes the potential for a problem.
The air intake on the west wall of the DCP far" ty is positioned high on the facility at an elevation of approximately 93 feet. This places it high above the ground and the effects of ground level vapor. Additionally it places it above the FMO/FMOX roof line and thereby removing it from most of the conditions that might be postulated relative to airflow around the complex of buildings. The selection was therefore felt to provide the cleanest air available for this system.
Additionally, the air intake system is outfitted with HF detectors. These detectors will detect HF at concentrations sufficiently low to protect workers.
Upon detection, an alarm is sounded in the control room and a signal is sent to the CSI control system which shuts down the air supply system.
Evacuation and other protective measures are then implemented using alarms, announcements and evacuation procedures.
Document Control Desk Oct~ober 7,1996 1
Page 2 of 2 1
l Item #2:
Follow-up and close-out of the Internal 1994 PSM Compliance audit findings and recommendations (issued January 4,1995) do not appear to have been completed.
i Response:.
All but one of the 27 findings identified during the 1994 PSM Compliance Audit have been resolved. Findings identified during the audit (referred to as 46/94-1 by GE) were each tracked internally on a monthly report that identified open items, the responsible person, the committed date, and the closed date. An archive of these audit findings and abatement dates is available. At the time of this writing, there is one open item being tracked on this report and is scheduled for close-out.
ltem #3:
Identify how all of the Individual PSM requirements and elements are i
being met by current plant programs, policies, procedures, and practices.
Response
A Process Safety Management descriptive document has been developed for the GE-Wilmington facility. This program addresses the individual elements required under 29 CFR 1910.119 and details how the standard's requirements are met on-site. Additionally, several procedures independent 1
of the PSM requirements (e.g. P/P #80-62 Hazard and Operability Assessment and Safety Procedure #503 - Cutting and Welding Permits and
)
Equipment Safety Review - Safety Procedure #118) have also been i
implemented on-site to fulfill not only the requirements of the PSM Standard, but to also ensure safe practices site-wide.
l item #4:
Determine how all of the individual management-approved PHA recommendations were completed, and consolidate the close-out actions taken.
During the preliminary phase of the Process Hazard Analysis (PHA), GE and Halliburton NUS determined that the Hazop findings with a ranking of 1 to 5 (high risk) would be forwarded to responsible engineers for tracking toward completion. GE's 1992 Process Hazard Analysis did not uncover any high priority findings for Anhydrous Ammonia and associated processes. Documentation of the PHA procedure, the activities of the Hazop steering committee, and the tracking of the PHA Recommendations are maintained in the FMO Configuration Management Center.
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